IR 05000382/1992023
| ML20126B229 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/14/1992 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9212220016 | |
| Download: ML20126B229 (4) | |
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UNITED STATES -
[p3 280g$\, NUCLEAR REOUL ATORY COMMISSION {
j , j REolONIV o 8 611 RYAN PLAZA DRIVE, SulTE 400 5, AR LINGTON, T E XAS 76011-8064 j/
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DEC I 4 1992
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Docket No. 50-382 License No. NPF-38 l l Entergy Operations, In ATTH: Ross P. Barkhurst, Vice President Operations, Waterford ; P.O. Box B Killona, Louisiana 70066 Gentlemen: SUBJECT: NRC INSPECTION REPORT NO. 50-382/92-23 Thank you for your letter of December 4,1992, in response to our letter and Notice of Violation dated November 4, 199 We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine
Sincerely, -
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A. Bill Beach, D rect'o Division of Re tor jects CC: Enttrgy Operations, In ATTN: Donald C. Hintz, President
& Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286 Entergy Operations, In ATTN: John P.. McGaha, Vice President Operations Support P.O. Box 31995 Jackson, Mississippi 39286 I
9212220016 921214 I PDR ADOCK 05000382 i G PDR
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Entergy-Operations, Ih;. -2-Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es P.O. Box 651 Jackson, Mississippi 39205 Entergy Operations, In ATTN: D. F. Packer, General Manager Plant Operations P.O. Box B-X111ona, Louisiana 70066 Entergy Operations, In . ATTN: L. W. Laughlin Licensing Manager P.O. Box B * Killona, Louisiana 70066 Chairman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 '
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Entergy Operations, In ATTN: R.-F. Burski, Director Nuclear Safety P.O. Box B Killona, Louisiana 70066 Hall-Bohlinger, Administrator Radiation Protection Division
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P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish ; P.O. Box 302 Hahnville, Louisiana 70057
- Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 Winston & Strawn ATTN: Nicholas S. Reynolds, Es L Street,- Washington,.D.C.- 20005-3502 l.. . . - - , - - , , , ,, .
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Entergy Operations, In DEC I 4 H)32 bec to DMB (IE01) bec distrib. by RIV: J. L. Milhoan Resident inspector DRP Section Chief (DRP/A) Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer (DRP/A) Section Chief (DRP/TSS) DRS G. F. Sanborn, E0 J. Lieberman, OE, MS: 7-H-5 ll l _
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. Entergy Operations, In DEC I 41992 bcc to DMB (1001) bec distrib. by RIV: J. L. Milhoan Resident inspector DRP Section Chief (DRP/A) Lisa Shea, RM/Alf, MS: MNBB 4503 MIS System DRSS-flPS RIV file Project Engineer (DRP/A) Section Chief (DRP/TSS) DPS G. F. Sanborn, E0 J. Lieberman, OE, MS: 7-H-5
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n. F. Dur ski W3fl-92-0461 A4.05 QA December 4,1992 U.S. Nuclear Regulatory Commission [ ~Dr ~ ATIN: Document Control Desk Washington, D.C. 20555
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Subject: Waterford 3 SES ;
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R 4 /992 Docket No. 50-382 L - License No NPI-38 . Tf"'nD -< ) NRC Inspection Report 92-23 , Reply to Notice of Violation
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Gentlemen: In accordance with 10CfR2.201, Entergy Operations, Inc. hereby submits in Attachment I the response to the violations identified in Appendix A of the subject inspection Report, in addition, your inspection report expressed concern over Violation 9223-03 in view of a similar violation identified in July, 1992. Although Entergy Operations, Inc. believes that the root causes of these two violations are unrelated, we share your concern. As a result, we have implemented or plan to implement corrective actions to increase worker's awareness of the importance of maintaining radiological posting Furthermore, we have formed a Quality Action Team (QAI) to improve radiological posting processe If you have any questions concerning this response, please contact C.J. Thomas at (504) 739-653 Very truly yours,
., vtwJ Rf0/CJT/ssf Attachment cc: lJ M Miiiioan'(NRCLRe0 ion:lV)I D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident inspectors Office l~ 0 }'l _-. k\QD%Dh* - - _ - _ - - - -
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Attachment to
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03ft-92-0161
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piping. According to the SRF, if any answer to these questions is YES, and the scaffold is built in any room / area identified by Attachment 9.5, then the SRF must be forwarded to the field Engineer for an engineering evaluation. Since Scaffold No. 12551 was installed directly over, and within 1/16 inch of the motor operator for Valve SI-226A, and was located in an area identified by Attachment 9.5, then a posterection engineering evaluation should have been performe A contributing cause of this event involves the instructions for - forwarding applicable SRfs to the field Engineer for a postarection engineering evaluation. These instructions are only provided at the bottom of the SRf and not in the body of NOCP-207. This condition may obscure the instructions ano allow them to be overlooked by the NOCS/ Designe It should be noted that this violation was identified 2 days prior ' to the Refuel 5 Outage. At that time, a large number of pre-outage:
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scaffolds were being erected and only one person was designated as the NOCS/ Designee responsible for reviewing all SRfs. This person failed to forward the SRf for Scaffold No. 12551 to the field ' Engineer for a posterection engineerin evaluation. Moreover, while ' implementing corrective measures for the violation, Nuclear Operations Construction (NOC) discovered that the NOCS/ Designee also failed to forward additional SRfs to the field Enginee (2) Corrective Steps That Have BeeLTaken and the Results Achieved Scaffold No. 12551 was dismantled on September 16, 1992. This was accomplished on the sar.c_ day the NRC Resident Inspector communicated
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the event to N0C. On' September 18, 1992, NOC completed training appropriate scaffold personnel on this event and on those requirements in NOCP-207 that relate to completing the SR Additionally, NOC performed a review of approximately 600 scaffold records on file. This review revealed that 101 scaffolds were erected with only pre-erection evaluations even though their completed SRfs indicated that posterection evaluations were required. As a result, NOC walked down and performed a posterection , evaluation on the scaffolds to ascertain if they were installed per N0CP-20 The walkdowns revealed that 2 of the 101 scaffolds did not meet procedure requirements. These scaffolds were promptly reconfigured. The remaining scaffolds were verified to be installed , per NOCP-207. These actions were completed by September 30, 199 l l _ _ _ _ - - _. : a
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l . f Entetgy Operobone. in ENTERGY ,,,
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I _ _ _ . _ n. r. ourou W31'l-92-0461 A4.06 QA December 4,1992 U.S. Nuclear Regulatory Commission f ;%. s ATIN: Document C:entrol Desk Washington, D.C. 20555 lf j j,[ ~~"yM
/c jj ,[d 'p; i gi Subjec t: Waterford 3 SLS [ ; $92 Docket No. 50-382 L ~. _ , ,
License No. NPF-38 _, T T.^!g,y y -'
NRC Inspection Report 92-23 - __
Reply to Notice of Violation Gentlemen: In accordance with 10Cf R2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violations identified in Appendix A of the subject inspection Repor In addition, your inspection report expressed concern over Violation 9223-03 in view of a similar violation identified in July, 1992. Although Entergy Operations, Inc. believes that the root causes of these two violations are unrelated, we share your concern. As a result, we have implemented or plan to implement corrective actions to increase worker's awareness of the importance of maintaining radiological posting Iurthermore, we have formed a Quality Action team (QAT) to improve radiological posting processe If you have any questions concerning this response, please contact C.J. Thomas at. (504) 739-653 Very truly yours,
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7 w[ RfB/CJ1/ssf Attachment ' cc: lJXEM'i1'ho~an (NRC.RegioitelV)T D.L . Wigginton (NRC-NRR), R.B. McGehee, N.S. Reynolds, NRC Rcsident inspectors Office Q <j
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Attachment to W3F1-92-0461 Page 1 of 7 4
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ATTACHMENT 1 ENTERGY OPERATIONS, INC RESPONSE 10 THE VIOLATIONS IDENTIFIED IN
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APPENDIX A Of INSPECil0N REPORT 92-23 VIOLATION NO. 9223-01 !
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Technical Specification 6.8.1 requires, in part, that written procedures i be established, 'mplemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2. February 197 Section 1 of Appendix A of Regulatory Guide 1.33 Revision 2, February 1978, requires safety-related activities to be covered by written procedures, which include erecting scaffolds in the proximity of safety-related equipmen Attachment 9.1 of Nuclear Operations Construction Procedure NOCP-207, Revision 4, " Erecting Scaffold,' requires an engineering evaluation to be performed if a scaffold is built over equipment, valves, or piping or if installed within 1 inch of adjacent equipmt.nt.
' Contrary to the above, on September 16, 1992, the inspectors found Scaffold No.12551 installed directly over, and within 1/16. inch of, the safety-related motor operator for safety injection flow control Valve SI-226A. An engineering evaluation was not done, calling to question the-seisraic qualification and, therefore, the operability of high pressure safety injection Train RESPONSE (1) Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause was personnel error in completing the_ Scaffold Request form (Attachment 9.1 of NOCP-207) for Scaffold No. 1255 Two mistakes-were made when completing the Scaffold Request Form (SRF) _for Scaffold No. 12551, first, the Construction Foreman who supervised erection of-Scaffold No. 12551 incorrectly answered N0 to the question that' asks if the scaffold is installed with a < one-inch gap from adjacent equipment. Second, the Nuclear Operatioqs Construction-Supervisor (N0CS)/ Designee who reviewed.the SRF did not forward it to the Field Engineer for an engineering evaluation although the Construction. foreman had answered YES to the question that.asts if the scaffold-is installed over equipment, valves, or
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Attachment to a W3ft-92-0461 t
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piping. According to the SRf if any answer to these questions is
' (C!,e and the scaffold is built in any room / area identified by Attachrent 9.5, then the SRf must be forwarded to the field Engineer for on engineering evaluation. Since Scaffold No. 12551 was installed directly over, and within 1/16 inch of the motor operator for Valve S!-226A, and was located in an area identified by Attachnent 9.5, then a posterection engineering evaluation should have been perform-t A contdbuthy cause of tLis event involves the instructions for forward),ts applicab'e SRfs to the field Engineer for a posterection engineering evaluation. The$e instructierts are only provided at the bottom of the *>RT cid not N the body of NOCP-207. This condition may obscure the instructious and allow them to be overlooked by the NOCS/ Designe It should ht noted that this violation was identified 2 days prior
' to the Rsfuel 5 Outage. At that time, a large number of pre-outage scaffolds were being erected and only one person was designated as the NOCS/0esignee responsible for reviewing all SRfs. lhis person failed to forward the SRf for Scaf fold No.12551 to the field Engineer for a posterection engineering evaluation. Moreover, while implementing correctiv6 measures for the. violation, Nuclear Operations Construction (NOC) discovered that the NOCS/ Designee also failed to forward additional SRfs to the field Enginee (2) Corrective Steps That Have Been Taken and the Results Achieved Scaffold No. 12551 v:at dismantled on September 16, 1992, this was accomplished on the san >e day the NRC Resident inspector communicated the event to NOC. On September 18, 1992, NOC completed training appropriate scaffold personnel on this event and on those requireme.its in NOCP-207 that relate to completing the SR Additionally, NOC performed a review of approximately 600 scaffold records on file. This review revealed that 101 scaffolds were
crected with only pre-erection evaluations even though their completed SRfs indicated that posterection evaluations were required. As a result, NOC walked down and performed a posterection evaluation on the scaf folds to ascertain if they were installed per NOCp-20 The walkdowns revealed that 2 of the-101 scaffolds did not meet procedure requirements. These scaffolds were promptly reconfigured. The' remaining scaffolds were verified to be installed per NOCP-207. These actions were completed by September 30, 1992.- _ i
Attachment to - W3ft-92-0461 ' Page 3 of 7 .
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(3) Corrective Steps Which Will Be Taken to Avoid further Violations The body of NOCP-207 will be revised to incorporate instructions for forwarding applicable SRfs to F. eld Engineet ing for posterection engineering evaluations. Furthermore, ths SRF will be human factored to provide additional assurance that these instructions are'
not overlooke (4) Date When full Compliance Will Be Achieved full compliance wil) be achieved by March 31, 1993.
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W3F1-92-0461
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VIOLATION NO. 9223-02
!cchnical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, february 197 Section 1.1 of Appendix A of Regulatory Guide 1.33, Revision 2, february 1978, requires that the Plant fire Protection Program be covered by written procedure Section 6.4 of fire Protection Procedure FP-001-017, Revision 8, I " Transient Comhustibles and Designated Storage Areas," requires, in part, that the packing materials from equipment or supplies unpacked in a safety-related area be removed from the safety-related area immediately following the unpacking and that untreated combustible packing materials not be left unattended during lunch breaks, shift changes, or similar period Contrary to the above, on October 6, 1992, the inspector found untreated wood pallets and cardboard boxes, used to pack the new batteries,.in the space outside the AB switchgear cage where the battery rooms are locate he inspector noted that there was no one around to watch the material and that the material appeared to be staged for removal. When the inspector returned to the area the next morning, 14 hours later, the combustible ,
materials were still staged and, again, the material was unattende RESPONSE (1. ) Reason for the Violation Entergy Operations, Inc.-admits this violation and believes that the root cause was inappropriate action in that personnel involved with Design Change (DC) 3362 failed to recognize and adhere to the requirements of fP-001-01 DC 3362, " Station Battery Replacement," was implemented during the Refuel 5 Outage to replace Station Battery 3AB-S with a new battery of a similar type and capacity and to upgrade Station Batterier 3A-S and 3B-5. Implementation of this DC required that several plant departments identify and adhere to those requirements applicable to their assigned tasks. However, this was not-don . ._ . , . . _ _ ._ . , -- - , . . . _ , - , _ . ,, -
Attachment to W3f1-92-0461 - Page 5 of 7
. (2) Corrective Steps That Have Been Taken and the Results Achieved On October 7, 1992, the untreated wooden pallets and cardboard boxes were removed from the area outside the AB switchgear cag Subsequent to removing these combustible materials, work controls were established to ensure continued compliance with the requirements of fP-001-017. On October 15, 1992, a Transient Combustibles Permit was generated and a continuous fire watch was assigned to keep watch over the combustibles brought into the area to facilitate installation of the new 30-5 Batter On October 16, 1992, Quality Notice QA-92-120 was generated to document this condition adverse to quality. Furthermore, the Maintenance Superintendent discussed the need for timely initiation of corrective action documents with his direct reports during a staff meeting on November 17, 199 (3) Corrective Steps Which Will Be Taken to Avoid further Violations four specific actions are planned to prevent recurrence. First, this event will be discussed with Maintenance and Modification &
Construction personnel during group meetings to ensure that similar conditions are promptly recognized and appropriate actions take Second, this event will be discussed during site wide safety meetings to accentuate lessons learned. Third, FP-001-017 will be reviewed to provide additional assurance that the procedure contains sufficient guidance to ensure that fire protection requirements are clearly defined. Finally, Quality Notice QA-92-120 will be distributed to selected management personnel to remind them of the need to initiate corrective action documentation when the situation is appropriate or as circumstances dictat (4) Date When full Compliance Will Be Achieved full compliance will be achieved by february 26, 1993, l l l l l l \ l .
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W3ll-92-0461
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V101Al10N NO. 9??3-03 lechnical Specification 6.8.1 requises, in part, that written procedures be established, implemented, and maintained (overing the activities ref erenced in Appendix A of flegulatory Guide 1.33 Revision 2, lebruary 197 Section 7.e.(4) of Appendix A of Regulatory Guide 1.33, Revision 2, february 1978, requires that radiation protection procedures be established for contamination contro Section 5.3.2 of Administrative Procedure RP-001-219, " Radiological posting Requirements," requires that each radiation area be posted with a ~ sign or signs bearing the radiation symbol and the words: CAUTION RADIATION ARl: Contrary to the above: On October 6, 1992, the inspector determined that the boundary chain f or a radiation controlled area posting f or the post Accident Sampling Point Skid on the 421-foot level of the reactor auxiliary building was down and, therefore, did not clearly demarcate the radiation controlled are . On October 8, 1992, the inspector determined that a radiation area posting on the -35-foot level in the northwest corner of the fuel handling building was not properly posted in that the area could be entered or material removed without seeing the postin RESP 0NSl; -
(1) Reason fo_r the Violation intergy Operations, Inc. admits this violatio On November 13, 1992, a Quality Action Team (QA1) was formed to respond to this violation and to improve radiological posting processe The team, comprised of employees who are directly involved with radiological posting processes, determined that the root causes of the two conditions cited are not related.
- lhe QAT determined that the root cause of the first condition (e.g., downed radiation controlled area boundary chain) is an inadequate procedure in that UNI-005-072, "RCA Access Control," does not provide instructions to radiation workers relative to maintaining radiological boundarie .
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for the second condition (iroproper posting), the QAT determined that the root cause was a non-conservative assumption when posting the area, it was assumed that the area shelving could function as a physical boundary adequate to prevent inadvertent entry into this radiation area / hot particle storage area. This is understandable considering that it is unlikely that workers would try to crawl through the shelving to gain access into the are (2) Corrective Steps that Have Been Taken and the Results Achieved The NRC Resident 1nspector restored the boundary chain for the radiation controlled area posting for the Post Accident Sampling System Skid. Additionally, on November 12 and 17, 1992, llealth Physics technicians walked down other neas of the plant to identify similar problems with radiological Soundaries. During the walkdowns on November 12, 1992, two compromised boundaries (e.g., radiological ropes on the floor) were identified in the fuel Handling Buildin These boundaries were immediately restored. No other instances of downed boundaries were identifie Furthermore, this event was discussed at the November $afety Meetings ar..' a memorandum was issued from the Plant Manager to plant workers to increase worker's awareness of the importance of maintaining radiolooical boundarie The radiation area posting on the -35-foot level in the northwest corner of the fuel handling building was properly posted to prevent inadvertent entry. A radiological rope was extended across the open area of shelving with a ra,liological posting describing the area.
(3) Corrective Steps Which Will Be Taken to Avoid Further Violations four specific actions are planned to prevent recurrence. First, UNT-005-022 will be revised to provide instructions to radiation workers relative to maintaining radiological boundaries / posting Next, General Employee Training will be revised to provide additio..al information on the importance of maintaining radiological boundaries / posting Third, this event will be discussed with the staff Health Physics technicians during the December departmental meetin Finally, Health Physics will revise HP-001-219 to include additional guidance on what constitutes appropriate posting.
(4) Date When full Compliance Will Be Achieved full compliance will be achieved by March 31, 1993. }}